This year has brought significant momentum in the U.S. and around the world on the question of how gluten should be labeled on food products. The Celiac Disease Foundation has been a key voice in these discussions, submitting comments to the U.S. Food and Drug Administration (FDA), participating in global Codex Alimentarius conversations, and working alongside partners to push for labeling that is clear, consistent, and protective for people with celiac disease.
While we’ve covered the progress made globally in a separate post, here is what we’ve been up to in the United States.
Labeling and Preventing Cross-Contact of Gluten for Packaged Foods
In January, the FDA asked the public for input on labeling and preventing cross-contact of gluten in packaged food.
In our comment, submitted alongside eight partner organizations, we shared the results of a consumer survey we conducted in early 2026 (see key results here) and made four key recommendations to the FDA:
- Keep the existing gluten-free standard of <20 ppm gluten in finished food products while improving transparency and consistency in how gluten sources and cross-contact risks are communicated on labels.
- Keep the current regulatory treatment of oats. Oats are naturally gluten-free; any risk from eating oats comes from cross-contact with wheat, barley, or rye during production and processing. However, the current gluten-free standard remains protective in this situation, and gluten-free labeled oats are tolerated by most individuals with celiac disease. For more information on oats, please see here: Gluten-Free Oats: What’s the Deal? | Celiac Disease Foundation
- Require barley and rye to have the same labeling requirements as those classified as major food allergens. Since barley and rye are not currently classified as major food allergens in the U.S. like wheat is, they often are not as clearly identified on ingredient labels. This can lead to accidental consumption of gluten, especially when gluten is hidden in ingredients like malt extract.
- Standardize any precautionary labeling. Statements like “may contain wheat,” “made in a facility with wheat,” and “processed on shared equipment” are currently voluntary and inconsistent. If the U.S. moves forward with precautionary labeling, we recommended clearer, standardized language that helps people make safe choices without unnecessary fear and confusion.
This comment was submitted together with our Scientific Advisory Committee, the Society for the Study of Celiac Disease and valued partners the American Gastroenterological Association, NASPGHAN, the Gluten Intolerance Group, FARE (Food Allergy Research & Education), the Digestive Disease National Coalition, the Bone Health & Osteoporosis Foundation, and the Center for Science in the Public Interest.
Food Allergen Thresholds and Their Potential Applications
In February, the FDA held a virtual public meeting to explore the idea of adopting food allergen thresholds, which are specific amounts of an allergen below which there is most likely not a reaction and therefore a precautionary label (like “may contain”) would not be required.
As mentioned above, “may contain” statements are applied inconsistently. Some manufacturers add them out of an abundance of caution even when the risk of actual exposure is extremely low, while others don’t use them at all. A threshold-based system would mean precautionary labels are only required when there is a meaningful risk, making those warnings more useful.
In our comment, we made three recommendations:
- Include gluten and celiac disease in this framework now. Because small, repeated exposures to gluten can cause cumulative intestinal damage over time in celiac disease, which is different than risks of typical food allergies, it is important for celiac disease to be part of the framework from the start rather than trying to fit it in to a food allergen framework later.
- Adopt the internationally-supported reference dose for gluten. If the FDA moves forward with precautionary labeling requirements, we recommend they use the 4 mg gluten reference dose established by the FAO/WHO in November 2025, meaning a precautionary label would be required when a product could expose someone to 4 mg or more of gluten in a serving from cross-contact. This threshold was also recently advanced at the international Codex Alimentarius meeting, marking a significant step toward global adoption.
- Pair any new thresholds with clear guidance, communication, and ongoing research. We recommended FDA provide guidance to manufacturers, especially for high-risk categories like baked goods, oats, and spices, and commit to consumer education and continued research to ensure thresholds remain protective as evidence evolves.
Moving Forward
The FDA is now reviewing the comments received and considering next steps. In the meantime, there is exciting action in Congress that could also improve food labeling. The Food Labeling Modernization Act (H.R. 8385), recently re-introduced by Representatives Frank Pallone (NJ) and Rosa DeLauro (CT), would require food packaging to disclose gluten-containing grains in the ingredient list. This bill alignswith our recommendations to FDA listed above and can be accomplished through FDA taking action themselves or through this legislative action. More information about this and future legislation, as well as how you can help advocate for its passage, is forthcoming.